CSRD Agreed: A Major Recalibration Of The EU Sustainability Reporting Regime – Corporate and Company Law

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On 16 December 2025, the European Parliament adopted a significantly streamlined version of the Corporate Sustainability Reporting Directive. This represents a very significant recalibration of the EU’s sustainability reporting regime.


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Corporate/Commercial Law


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On 16 December 2025, the European Parliament adopted a
significantly streamlined version of the Corporate Sustainability
Reporting Directive (“CSRD”). This represents a very
significant recalibration of the EU’s sustainability reporting
regime.

CSRD’s evolution

The CSRD represents the EU’s flagship framework for
mandatory sustainability reporting. Originally designed to apply to
a broad range of EU and non‑EU companies on a phased basis
from 2025, CSRD requires in‑scope entities to report in
accordance with the European Sustainability Reporting Standards
(“ESRS”) and to apply the
“double‑materiality” test. This test requires
companies to assess both financial materiality, how sustainability
matters affect the company and impact materiality, and how the
company affects people and the environment. The reporting
requirements spans governance, strategy,
impacts/risks/opportunities and metrics/tarobtains, extfinishs across the
value chain, and is subject to limited assurance.

In February 2025, the European Commission launched its
“Omnibus” initiative as part of a wider simplification
agfinisha intfinished to reduce reporting burdens for companies. The
Omnibus put forward by the European Commission contained a
substantial scaling‑back of CSRD, triggering nereceivediating
positions to be found by the Council of European Union and the
European Parliament. Trilogue nereceivediations between the European
Commission, the Council of the European Union and the European
Parliament proceeded at pace throughout the finish of 2025.

Now, on 16 December 2025, the European Parliament has voted
through the revised CSRD.

Key features of the revamped CSRD

  • EU company scope: Under the amfinished CSRD, EU
    companies fall within scope only if they exceed EUR 450 million net
    turnover and have 1,000 employees at the entity or
    consolidated level. This marks a very significant narrowing from
    the original framework and is expected to reduce the number of
    mandatory reporters by at least 80%.

  • Non‑EU company scope: Non‑EU
    parent groups must report where their EU net turnover exceeds EUR
    450 million, and they have an EU subsidiary or branch generating at
    least EUR 200 million turnover. In‑scope non‑EU groups
    must prepare a sustainability report at the group level.

  • Application timelines: Member States may
    exempt companies that fall below the new scope thresholds from
    reporting obligations for financial years 2025 and 2026. The
    revised scope will apply in full from financial year 2027.

  • Revised ESRS: A new, simplified set of ESRS
    must be adopted within six months of the
    CSRD’s entest into force. The revised standards are expected to
    reduce datapoints, prioritise quantitative disclosures, clarify
    materiality expectations and enhance interoperability with other
    global frameworks.

  • Value‑chain disclosures: The revised
    framework introduces “value‑chain caps” that limit
    the information companies may require from value‑chain
    entities with fewer than 1,000 employees. Companies will retain a
    three‑year transition period during which estimates may be
    utilized where complete information cannot be obtained.

  • Assurance and implementation support:
    Limited‑assurance requirements remain in place, with EU
    assurance standards due by 1 July 2027. A new EU sustainability
    reporting portal will also be established to support
    implementation. Reporting thresholds will be subject to periodic
    adjustment for inflation.

What This Means in Practice

Overall, the amfinished CSRD significantly reduces the number of
companies subject to mandatory EU sustainability reporting.

Companies currently preparing for CSRD should reassess their
potential in‑scope status under the new thresholds, monitor
Member State implementation decisions for the 2025–2026
exemptions and prepare for the revised ESRS expected in
mid‑2026.

CSRD Agreed: A Major Recalibration Of The EU
Sustainability Reporting Regime

The content of this article is intfinished to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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